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HMRC internal manual

Inheritance Tax Manual

From
HM Revenue & Customs
Updated
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Definition and extent of liability (PETs): objects of a discretionary trust

Where property is settled by the transfer, IHTA84/S199 (1)(d) imposes liability on any person for whose benefit the settled property, (IHTM16000) or income from it, is applied (IHTM30037). The liability extends to the amount of the property or income. The amount is net of any income tax paid.